EBA Q&A 2021_6301 concluded that a natural person qualifies as an SME only in respect of the economic activity carried out, and that exposures financing private activities of that person do not benefit from the SME supporting factor. That conclusion rested on the then-applicable wording of Article 501(2)(b) CRR, which defined an SME by reference to Commission Recommendation 2003/361/EC.

Regulation (EU) 2024/1623 replaced that wording. Article 501(2)(b) CRR now provides that an SME has the meaning laid down in Article 5, point (9), CRR, which defines an SME as a company, enterprise or undertaking whose annual turnover, according to its most recent consolidated accounts, does not exceed EUR 50 000 000. The reference to Recommendation 2003/361/EC — and with it the "engaged in an economic activity" wording on which the 2022 answer was constructed — no longer forms part of Article 501.

Under the Italian statistical framework counterparties are assigned a single identifier and a single sector classification, and anti-money-laundering requirements oblige institutions to identify and monitor customers at counterparty level. Assessing SME status exposure by exposure for a single obligor would therefore require a parallel, purpose-based classification with no counterpart elsewhere in the reporting framework.